Note that if you are an investor or potential investor in one of our funds, you may also receive separate notices regarding our privacy practices concerning non-public Personal Information that we collect from you as an investor in us or in any funds that we sponsor or manage. The privacy practices contained in those notices to investors or potential investors are summarized below.
The following is a description of (1) the categories of Personal Information we may have collected in the preceding 12 months; (2) the sources from which we may have collected it; (3) the business purposes for which we may have collected it; and (4) with whom we share the personal information we collect.
Generally speaking, we may collect two types of data and information:
Personal Information: The first type is personal information that identifies, relates to, describes, or is reasonably capable of being associated with a particular individual or a household. Although not all of the following are applicable to each User, the categories and types of Personal Information that we may collect either online or off-line include:
Non-personal Information: The second type is non-personal information that is un-identified and non-identifiable information pertaining to Users that may be made available or gathered by your use of the Site. Non-personal Information may include your aggregated usage information and technical information transmitted by your device, including certain software and hardware information (e.g., the type of browser and operating system your device uses, language preference, access time, etc.) in order to enhance the functionality of our Site. We may also collect information on your activity on the Site (e.g., pages viewed, clicks, actions, etc.). We do not know the identity of a User from which Non-personal Information is collected.
We may use Personal Information that we collect from or about you for any of the following business purposes:
We will not use Sensitive Personal Information that we collect from or about you for any other business purpose other than described above.
We do not sell, disclose, or share our Users’ Personal Information with any third parties for their own use, and have not done so for the preceding 12 months.
We will not use disclose, share, or transfer your Personal Information with or to any other person or entity, except as follows:
In the event of a sale, assignment, or transfer of our assets or of any portion of our business, we reserve the right to transfer any and all information that we collect from individuals, or that we otherwise collect in connection with the Site, to unaffiliated third-party purchasers.
Any Personal Information you provide us, such as identifiers or employment history, when applying for a career position with the Company will be used solely to consider and act upon your application. We may retain your Personal Information for a period of time, but only for as long as necessary for such purposes, please see Data Retention and Rectification section below. We may disclose your Personal Information to our service providers for the purpose of evaluating your qualifications for the particular position you applied for, or other available positions.
We may use your Personal Information, such as your name, email address, telephone number, etc. ourselves or through our service providers for the purpose of providing you with promotional materials concerning our products or services that we believe may interest you. We provided within such marketing materials a means by which to decline receiving further promotional materials from us. If you unsubscribe from these materials, we will remove your email address or telephone number from our marketing distribution lists.
You may receive emails from the Company for a variety of other reasons. If you have an account with the Company on the Site, you can select your preferences through your account settings. You can also manage your receipt of certain types of communication by following the instructions included in the email we send you. Alternatively, you may contact us at email@example.com with the word “UNSUBSCRIBE” or “REMOVE” in the subject line. Your email address will be removed from our marketing list. Please allow us a reasonable period of time in order to satisfy your request. Please note that, even if you unsubscribe from certain email correspondences, we may still need to email you with important transactional or administrative information.
If you have an account on the Site, you can see, review, and change most of your Personal Information by logging into your account on the Site and editing your Account Profile or by contacting us at the addresses in "How To Contact Us." NOTE: California Residents who wish to make a consumer rights Request to Know, Request to Delete, Request to Access, or Request to Correct their data should follow the instructions in the "California Residents" sections of this Policy, below.
We will retain your Personal Information for as long as necessary to provide our services, comply with our legal obligations, resolve disputes, and enforce our policies, as outlined in the below Retention Schedule. Retention periods will be determined taking into account the type of information that is collected and the purpose for which it is collected, bearing in mind the requirements applicable to the situation and the need to destroy outdated, unused information at the earliest reasonable time. Under applicable regulations, we will keep records containing client personal data, account opening documents, communications, and anything else as required by applicable laws and regulations. We may rectify, replenish, or remove incomplete or inaccurate information, at any time and at our own discretion.
|Personal Information Collected||Retention Period|
|Device Information (e.g., IP addresses, geolocation data, unique identifiers)||2 years|
|Housing Application Information and supporting data from client||10 years|
|Low income housing tenant application and related documentation||Permanent|
|Financial Services Information||5 years|
|Client Login and Site Registration||5 years|
|Job Applications for hired employees||10 years|
|Job Applications for non-hires||5 years|
We understand the importance of protecting children’s privacy, especially in an online environment. The Site is not designed for or directed at children. You must be at least eighteen (18) years of age to use our Site and the Company’s services. If you are not at least 18 years of age, please do not provide any Personal Information through this Site. Under no circumstances shall we allow the use of our services by minors without prior consent or authorization by a parent or legal guardian. We do not knowingly collect Personal Information from minors or children. If a parent or guardian becomes aware that his or her child has provided us with Personal Information without their consent, he or she should contact us, below.
If you have any general questions about the Site or the information we collect about you and how we use it, you can contact us at firstname.lastname@example.org, at 1-866-566-9438, or at the following address:
Hunt Companies, Inc.
Attention: Chief Compliance Officer
1330 Avenue of the Americas 28th Floor
New York, NY 10019
Pursuant to the Gramm-Leach-Bliley Act (“GLBA”), Pub. L. No. 106-102, the rule issued by the Securities and Exchange Commission regarding the Privacy of Consumer Financial Information (Regulation S-P) 17 C.F.R. Part 248, and/or the rule issued by the Federal Trade Commission regarding the Privacy of Consumer Financial Information, 16 C.F.R. Part 313, institutions that provide certain financial products or services to individuals to be used for personal, family, or household purposes are required to provide written notices to their customers regarding disclosure of nonpublic personal information. This notice is being provided to you to comply with this requirement.
We understand that it is our obligation to maintain the confidentiality of non-public personal information with regard to our investors. As a consequence, we do not disclose any non-public personal information about our investors or former investors to anyone other than our affiliates and service providers, except as permitted by law. Affiliates are companies related by common ownership or control and can be financial or nonfinancial companies. Service providers include businesses such as our attorneys, accountants, and entities that assist us with the distribution of stock to our investors.
Furthermore, consistent with industry practice, we will continue to distribute certain non-public personal information, such as the schedule of investors to the fund agreement and capital account information for all investors in each specific fund, to any regulatory authority having jurisdiction over us or any of our funds; or in connection with any litigation or other dispute or otherwise as necessary or appropriate to enforce the terms of our agreements with you.
In order to accurately and efficiently conduct the fund’s investment program, we must collect and maintain certain non-public personal information about you and the fund’s other investors and former investors. We collect, and may disclose to our affiliates and service providers (e.g., our attorneys, accountants, and entities that assist us with the distribution of stock to our investors) on a “need to know” basis, certain non-public personal information about you from the following sources:
To the extent authorized by law, we also may disclose non-public personal information to other nonaffiliated companies for our everyday business purposes, such as to process transactions, maintain accounts, respond to court orders and legal investigations, or report to credit bureaus.
The State of California enacted the Shine the Light law (CA Civil Code § 1798.83) that permits customers who are California residents to request certain information regarding our disclosure of personal information during the past year for marketing purposes. To make such a request, please send an email to email@example.com or call 1-866-566-9438.
The California Consumer Privacy Act of 2018, Cal. Civ. Code §1798.100 et seq., (“CCPA”) took effect on January 1, 2020 and grants new privacy rights to California consumers. The California Privacy Rights Act of 2020 (“CPRA”), is a California ballot proposition that voters approved, which expands and builds on the CCPA and went into effect on January 1, 2023. Together, the CCPA and the CPRA provide California consumer rights, including:
A business subject to the CCPA that collects a California consumer’s Personal Information must, at or before the point of collection, inform the consumer as to the categories of Personal Information to be collected and the purposes for which the categories of Personal Information shall be used.
A covered business must disclose and deliver the Personal Information the business collected about the consumer in response to a verifiable consumer request
For purposes of the CCPA, “Personal Information” does not include:
A further summary of consumer rights provided by the CCPA follows.
A business that collects Personal Information must also disclose, in response to a verifiable consumer request, the following:
A business that sells or shares a consumer’s Personal Information or discloses a consumer’s Personal Information for a business purpose must disclose the following in response to a verifiable consumer request:
California consumers have the right to request that a business that maintains inaccurate Personal Information about the consumer correct that inaccurate Personal Information, considering the nature of the Personal Information and the purposes of the processing of the Personal Information. A business must use commercially reasonable efforts to correct inaccurate Personal Information as directed by the consumer.
You have the right to request that we delete any of your Personal Information that we collected from you and retained, subject to certain exceptions. Once we receive and confirm your verifiable consumer request, we will delete (and direct our Service Providers to delete) your Personal Information from our records, unless an exception applies.
However, the CCPA provides for certain exceptions to the Right to Deletion. We may deny your deletion request if retaining the information is necessary for us or our Service Providers to:
California consumers may obtain a copy of their Personal Information that the consumer previously provided to a business in a portable and, to the extent technically feasible, readily usable format that allows the consumer to transmit the data to another business without hinderance.
A business must not discriminate against a consumer who exercises any of the consumer’s rights under the CCPA. However, a business may charge different prices or provide a different quality of goods or services if the difference is reasonably related to the value provided to the consumer by the consumer’s data and may offer financial incentives to a consumer for the collection, sale, or deletion of Personal Information on a prior opt-in consent basis.
If a business sells consumers’ Personal Information to third parties, then the business needs to provide notice to consumers thereof and that consumers have the right to opt out of the sale of their Personal Information. Such a business must provide a “Do Not Sell My Personal Information” link on its Internet homepage that links to an Internet webpage that enables a consumer to opt out of the sale of the consumer’s Personal Information.
A business must not sell the Personal Information of consumers if the business has actual knowledge that the consumer is less than 16 years of age, unless the consumer, in the case of consumers between 13 and 16 years of age, or the consumer’s parent or guardian, in the case of consumers who are less than 13 years of age, has affirmatively authorized the sale of the consumer's Personal Information.
You have the right to limit the Company’s use and disclosure of sensitive Personal Information to that which is necessary for providing products or services to you. You can click on the link titled “Limit the Use of My Sensitive Personal Information” which will take you to a page that enables you to limit the use of sensitive Personal Information to only that which is essential for providing goods or services.
Sensitive Personal Information includes any private information that divulges any of the following:
Publicly available information is not sensitive Personal Information under the CCPA.
If you wish to exercise any of the CCPA consumer rights summarized above, such as a Request to Know or a Request to Delete Personal Information, you can do so in one of the following ways:
Upon receiving a verifiable Request to Know or a Request to Delete, we will confirm receipt of the request within ten (10) business days and provide some information about how we will verify and handle the request, and by when you should expect to receive a response.
Please note that you may only make a verifiable consumer Request to Know or Request to Access your data under the CCPA two times within any 12-month period.
Of course, we need to be reasonably sure that the person making the request is actually you! So, we may need some information from you to verify that you are the person whose Personal Information you are asking to know about or to delete. Accordingly, the verifiable consumer request must:
We cannot respond to your request or provide you with Personal Information if we cannot verify your identity or authority to make the request and confirm the Personal Information relates to you. Making a verifiable consumer request does not require you to create an account with us. We will only use Personal Information provided in a verifiable consumer request to verify the requestor’s identity or authority to make the request. Requests to delete or to know specific household Personal Information will not be granted unless each member of the household is verified.
Only you or a person registered with the California Secretary of State that you designate and authorize to act on your behalf, may make a verifiable consumer request related to your Personal Information. For your protection, we will need some proof that someone seeking to act on your behalf is actually authorized by you to do so. You may also make a verifiable consumer request on behalf of your minor child.
We will try to respond to a verifiable consumer request within forty-five (45) calendar days of its receipt. If we need more time (up to a total of 90 calendar days), we will inform you of the reason and extension period in writing. If you have an account with us, we will deliver our written response to that account. If you do not have an account with us, we will deliver our written response by mail or electronically, at your option. Any disclosures we provide will only cover the 12-month period preceding the verifiable consumer request's receipt.
If you are making a Request to Delete your Personal Information, we may re-confirm with you that you really want your information deleted after verifying your request.
If we cannot respond to or comply with your Request to Know or Request to Delete, for instance, because we cannot verify your identity or because an exception applies, we will explain the reasons we cannot comply with your request. For data portability requests, we will select a format to provide your personal information that is readily useable and should allow you to transmit the information from one entity to another entity without hindrance.
We do not charge a fee to process or respond to your verifiable consumer request unless it is excessive, repetitive, or manifestly unfounded. If we determine that the request warrants a fee, we will tell you why we made that decision and provide you with a cost estimate before completing your request.